Overview of Federal Cost Allocation & Indirect Cost Rates (2 CFR Part 200) for The State of Washington

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1 Overview of Federal Cost Allocation & Indirect Cost Rates (2 CFR Part 200) for The State of Washington Presented by: MGT of America, Inc. Bret Schlyer, Director

2 Cost Principles and Requirements States/Territories and Local Governments 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles Appendix V State/Local Govt Central Service Cost Allocation Plans Appendix VI - Public Assistance Cost Allocation Plans Appendix VII States & Local Government Indirect Cost Proposals ASMB C-10 Implementation Guide for OMB Circular A

3 Federal Cost Principles (formerly OMB Circular A-87) Entered into Code of Federal Regulations (2 CFR Part 225) in August 2005, modified and moved to 2 CFR Part 200) in December of 2013 Applicable since 1969 Provides principles and procedures for the identification and recovery of Direct costs Government-wide indirect costs Agency/Department indirect costs Billed services 3

4 2 CFR Part 200 Structure Subpart A Acronyms and Definitions Subpart B General Provisions Subpart C Pre-Federal Award Requirements and Contents of Federal Awards Subpart D Post Federal Award Requirements Subpart E Cost Principles Subpart F Audit Requirements 4

5 Subpart A: Definitions Central Services Cost Allocation Plan the documentation identifying, accumulating, and allocating or developing billing rates based on the allowable costs of services provided by a state, local government, or Indian tribe on a centralized basis to its departments and agencies Indirect cost rate proposal the documentation prepared by a non-federal entity to substantiate its request for the establishment of an indirect cost rate 5

6 Subpart A: Definitions Pass through entity a non-federal entity that provides a sub award to a subrecipient to carry out part of a Federal program Subrecipient a non-federal entity that receives a sub award from a pass-through entity to carry out part of a Federal program; may also be a recipient of other Federal awards directly from a Federal awarding agency. 6

7 2 CFR Part 200: Effective Date for Cost Allocation and Indirect Rates Existing indirect rate agreements will remain in place until a newly re-negotiated rate goes into effect Non-Federal agencies can begin submitting cost allocation plans and indirect cost rates based on the 2 CFR Part 200 for fiscal years beginning after 12/26/14 7

8 Subpart B: Basic Principle The principles are designed to provide that Federal awards bear their fair share of cost recognized under these principles except where restricted or prohibited by statute 8

9 Subpart E: Policy Guides Application of sound management practices Responsible for administering federal programs in accordance with applicable policies and requirements. Proper and efficient program administration Accounting practices must be consistent with these cost principles, support the accumulation of costs, and provide for adequate documentation to support costs charged to the Federal award. 9

10 Subpart E: Application Federal awards Internal service fund billings Inter-agency billings Sub-awards must be used by the non-federal entity as a guide in the pricing of fixed-price contracts and subcontracts where costs are used in determining the appropriate price. 10

11 Subpart E: Basic Considerations Necessary and reasonable All activities charged uniformly Allocable Authorized under state or local laws Not otherwise restricted by statute Consistent treatment In accordance with GAAP Not included as a cost of another Federal award Net of all applicable credits Adequately documented 11

12 Subpart E: Direct & Indirect Costs Direct Cost - can be identified specifically with a particular final cost objective Indirect Cost - incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved

13 Subpart E: General Provisions for Selected Items of Cost Begins at Principles for establishing cost allowability Discussion on 55 cost items Should review all items, many include caveats. Today s presentation Discussion of unallowable cost items Discussion of costs which commonly incur audit/review findings 13

14 Subpart E: Unallowable Costs Advertising for public relations Advertising for recruitment, procurement, disposal/surplus materials, program outreach are allowable Alcoholic beverages Audit services Unallowable if required Single Audit is not conducted Unallowable if exempt from Single Audit. Bad debts Contingencies

15 Subpart E: Unallowable Costs (Continued) Contributions and donations Value of donated services or depreciation on property can be used to meet cost sharing or matching requirements Legal expenses related to claims against Federal government Entertainment Capital expenditures $5,000 and greater Fines and penalties Fund raising & investment management

16 Subpart E: Unallowable Costs (Continued) General government Governor or chief executive of entity Legislatures or governmental body Judiciary Branch Prosecutorial activities, fire and police Goods and services for personal use Idle facilities Allowable if necessary to meet workload fluxuations Allowable for 1 year if necessary at time acquired Lobbying Losses on other awards or contracts

17 Subpart E: Unallowable Costs (Continued) Interest on borrowed capital Allowable if to acquire capital assets Allowable in fiscal years beginning after Jan 1, 2016 if to acquire intangible assets, including patents & software. Country club, social or dining memberships Memberships in orgs with primary purpose of lobbying. Selling and marketing Self-assessed taxes that disproportionally impact federal programs Termination costs applicable to sponsored agreements (B.41) 17

18 Subpart E: Personal Services Compensation Must be reasonable Merit system Labor market compensation survey Incentive pay OK Fringe benefits Unused leave (termination or retirement) as indirect only Leave accrual - lesser of accrued or funded 18

19 Subpart E: Personal Services Compensation Post Retirement Health Benefits Must be treated as an indirect cost Severance pay Must be treated as an indirect cost Mass severance must have prior approval 19

20 Subpart E: Documentation of Personal Services Costs Documentation requirements are similar to A-87 rules, but less proscriptive Records must accurately reflect the work performed Internal controls assure that charges are accurate, allowable and properly allocated Incorporated into official records Reflect total activity for which employee is compensated Comply with established accounting policies & practices Budget estimates OK for interim accounting purposes if trued up Support the distribution of costs among specific activities if they work on multiple activities 20

21 Subpart E: Documentation of Personal Services Costs Types of multiple activities More than one federal award Federal award and a non-federal award An indirect activity and a direct activity Two or more indirect activities allocated differently An unallowable activity and a direct or indirect activity Signed personnel activity reports no longer required unless your existing system doesn t meet the criteria outlined in

22 Subpart E: Documentation of Personal Services Costs Personnel Activity Reports After the fact distributions Must account for total activities Prepared at least monthly Must coincide with one or more pay periods Must be signed by employee 22

23 Subpart E: Documentation of Personal Services Costs Substitute systems Random moment sampling Rolling Time studies Case counts Other quantifiable measures Must have prior approval 23

24 Subpart E: Depreciation Use Charge no longer allowed Capitalization policy Lesser of government policy or $5,000 Costs to be excluded Land Portion borne or donated by Federal government Any portion provided as a matching requirement Depreciation methods Straight line Other must be documented Physical inventories every two years 24

25 Subpart E: Idle Facilities All associated costs of idle facilities are unallowable Exception Necessary to meet fluctuations in workload Changes in program requirements Idle not to exceed 1 year 25

26 Subpart E: Interest Bona fide third party external to governmental unit Building completed after October 1, 1980 Equipment after September 1,

27 Subpart E: Proposal Costs Costs are allowable Normally to be treated as a government-wide or department indirect cost 27

28 Subpart E: Space Rental Normally allowable Must be reasonable rates Rates must be determined as if governmental unit continued to own for: Sale and lease-back Arrangements Less than arms length leases 28

29 Appendix V: State/Local Government Central Service Cost Allocation Plans Procedures and requirements for developing and submitting SWCAP or City/County-wide CAP Scope of CAP Submission requirements Documentation requirements Negotiation and approval process Other policies 29

30 Appendix V: State/Local Government Central Service Cost Allocation Plans Include all central service costs to be claimed Section I - Allocated Section II - Billed Omitted costs will not be reimbursed 30

31 Appendix V: State/Local Government Central Service Cost Allocation Plans States Submitted annually to CAS of DHHS Submitted within six months after year end Local Governments Submit annually if major local government >$100m in direct federal awards Prepare and retain for audit if not major Where local govt only receives federal money as subrecipient, the pass-through entity is responsible for monitoring the subrecipient s plan. 31

32 Appendix V: State/Local Government Central Service Cost Allocation Plans General Documentation Requirements Organization chart Comprehensive Annual Financial Report Audited financial statements Certificate of Cost Allocation Plan All allocated cost are allowable in accordance with Circular All costs are properly allocable to Federal awards Consistent treatment of costs Must be signed by an official who is authorized to legally bind the non-federal entity

33 Appendix V: State/Local Government Central Service Cost Allocation Plans Documentation required for allocated services Brief description of the service Identification of the unit rendering the service Operating agencies receiving the service Items of expense included in the cost Method used to distribute the cost Summary schedule of allocations to benefited agencies 33

34 Appendix V: State/Local Government Central Service Cost Allocation Plans Documentation for Billed Services Internal service funds with budget of >$5M Self-insurance funds Fringe benefits Other billed services Service descriptions, billing methodology, balance sheet, income statement, revenue by customer, Fund balance reconciliation 34

35 Appendix V: State/Local Government Central Service Cost Allocation Plans Negotiation & Approval Timely basis Review within six months of receipt Issuance of a central service cost allocation negotiation agreement Applicable to all Federal programs 35

36 Appendix V: State/Local Government Central Service Cost Allocation Plans Other Policies Each billed central service activity must maintain profit/loss financial statements. Each billed service allowed 60 day working capital reserve. Billed services required to annually adjust rates Requirements related to carry-forward adjustments. Record retention same as Subpart D of 2 CFR Part

37 Appendix VI: Public Assistance Cost Allocation Plans Detailed requirements presented in Subpart E of 45 CFR part 95 Only applicable to public assistance agencies Public assistance programs TANF, Medicaid, Food Stamps, Child Support Enforcement Narrative methodology approved by USDHHS Processed at least quarterly 37

38 Appendix VII: State/Local Government Indirect Cost Proposals Procedures and requirements for developing and submitting an agency/departmental ICRP An ICRP should include Information on department Schedules identifying and documenting the department s indirect costs Schedules documenting the calculation of one or more indirect cost rates Signed certificate of indirect costs 38

39 Appendix VII: State/Local Government Indirect Cost Proposals Submission Requirements Submission to federal cognizant agency required if receive more than $35M in direct federal funding Submitted within six months after year end Departments receiving less direct federal funding must prepare ICRP, but just retain for audit Pass-through agencies are responsible for negotiating and/or monitoring the ICRP of their subrecipients 39

40 Appendix VII: State/Local Government Indirect Cost Proposals Documentation Requirements Rate development information Subsidiary work sheets and other relevant data on indirect costs Work sheets should be referenced and reconciled to agency financial statements Work sheets providing the calculation of the indirect cost rate(s) 40

41 Appendix VII: State/Local Government Indirect Cost Proposals Documentation Requirements A copy of the financial data upon which the ICRP is based may require one or all of the following: Audited financial statements Comprehensive annual financial report Executive budget, accounting and/or payroll reports Amount of Federal costs included in direct cost base. Organizational information Organizational chart Functional statements noting the duties and responsibilities of all units Certificate of Indirect Costs Must be signed by an official who is authorized to legally bind the non-federal entity

42 Appendix VII: State/Local Government Indirect Cost Proposals Types of Indirect Cost Rates Predetermined Rate/Agreement Usually established for 2 to 4 years Not subject to adjustment Fixed with Carry-Forward Agreement Established for 1 year Requires reconciliation to actual Difference carried forward to subsequent year 42

43 Appendix VII: State/Local Government Indirect Cost Proposals Types of Indirect Cost Rates Provisional Temporary rate Requires annual reconciliation to actual Adjustments must be made to applicable period for each Federal award Very difficult to administer Final Based on actual cost of a period Used to close out provisional rates 43

44 Appendix VII: State/Local Government Indirect Cost Proposals Types of Indirect Cost Rates Flat 10% MTDC Rate any non-federal entity that has never received a negotiated indirect cost rate (and that has less than $35M in federal funding may elect to charge a deminimis rate of) 10% of modified total direct costs (MTDC) which may be used indefinitely. Interagency Services (10%) Department does not have an approved rate Only on salary and wage costs U.S. Department of Education Unrestricted In accordance with OMB Circular A-87 Restricted Excludes following Executive officer and their immediate office Staff reporting directly to Executive Officer Facility related costs 44

45 Appendix VII: State/Local Government Indirect Cost Proposals Rate Development Methods Simplified Single Rate for Department Agency-wide costs must benefit all programs Division costs must be consistent Usually a single indirect cost rate for the agency Multiple allocation base Multiple rates Agency indirect cost benefit varies Division indirect cost varies Different allocation base for each cost pool Cost pools only allocated to benefiting units Preparation of an indirect cost allocation plan Multiple rates Special indirect cost rates 45

46 Appendix VII: State/Local Government Indirect Cost Proposals Negotiation & Approval Timely basis Review within six months of receipt Issuance of an indirect cost rate agreement Applicable to all Federal programs 46

47 Appendix VII: State/Local Government Indirect Cost Proposals Other Policies Fringe benefit rates Billed services 47

48 2 CFR Part 200: Conclusion Not black and white document, even in its new form. Open to different interpretations Federal agency Negotiator Auditor Questions 48

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